Special NOFO
On June 22, 2022, HUD announced the Continuum of Care (CoC) Program Supplemental Notice of Funding Opportunity (NOFO) to Address Unsheltered and Rural Homelessness, which makes $322 million in competitive funding available to communities to address unsheltered and rural homelessness.
FAQs - Answered by HUD
As this Special NOFO is the first of it's kind, there may be questions that aren't clearly answered by the NOFO. KSHC will take these questions and send them to HUD to be answered. Please send all questions to seggert@kshomeless.com
IS A SSO PROGRAM A MIRROR OF THE PATH PROGRAM?
The PATH Program funds a variety of types of projects; therefore, this question is not possible to concretely answer. Additional information is below about the types of SSO projects that can be funded through this Special NOFO.
As provided in Section V.B.4.a of the Special NOFO, Supportive Service Only (SSO) projects are eligible to be funded under this NOFO. Eligible SSO projects include SSO-Coordinated Entry, SSO-Street Outreach, and SSO-Standalone.
As provided at 24 CFR 578.37(a)(3), SSO projects provide supportive services to unsheltered and sheltered homeless persons for whom the recipient or subrecipient is not providing housing or housing assistance.
All SSO projects awarded under this Special NOFO must follow the requirements of the CoC Program at 24 CFR Part 578, and not the requirements established for the PATH program.
Keep in mind, all projects must support the CoC's Plan as required by Section II.B.4.c of this NOFO. This means any project submitted as part of the CoC's application must support the CoC's Plan to Serve Individuals and Families Experiencing Homelessness with Severe Service Needs.
As provided in Section V.B.4.a of the Special NOFO, Supportive Service Only (SSO) projects are eligible to be funded under this NOFO. Eligible SSO projects include SSO-Coordinated Entry, SSO-Street Outreach, and SSO-Standalone.
As provided at 24 CFR 578.37(a)(3), SSO projects provide supportive services to unsheltered and sheltered homeless persons for whom the recipient or subrecipient is not providing housing or housing assistance.
All SSO projects awarded under this Special NOFO must follow the requirements of the CoC Program at 24 CFR Part 578, and not the requirements established for the PATH program.
Keep in mind, all projects must support the CoC's Plan as required by Section II.B.4.c of this NOFO. This means any project submitted as part of the CoC's application must support the CoC's Plan to Serve Individuals and Families Experiencing Homelessness with Severe Service Needs.
CAN YOU APPLY FOR FUNDS TO COMPLETE THE BUILDING OF EMERGENCY SHELTER COTTAGES?
No, under this Special NOFO funds cannot be used to acquire, construct, or rehabilitate structures to be used as emergency shelters.
As provided in Section V.B.4.a of the Special NOFO, CoCs may apply for the following types of projects through this NOFO:
As provided in Section V.B.3.e. of the Special NOFO, under the Rural Set Aside, a project may request funding to provide short-term emergency lodging in motels or shelters, either directly or through vouchers. Eligible costs include:
As provided in Section V.B.4.a of the Special NOFO, CoCs may apply for the following types of projects through this NOFO:
- Permanent Housing, including PSH and RRH
- Joint PH: RRH and TH Component Projects
- Supportive Services Only, including coordinated entry, street outreach, and standalone SSO projects
- HMIS
As provided in Section V.B.3.e. of the Special NOFO, under the Rural Set Aside, a project may request funding to provide short-term emergency lodging in motels or shelters, either directly or through vouchers. Eligible costs include:
- lodging in motels or hotels for program participants;
- pro-rata share of sheltering program participants in existing shelters so long as the costs are actual costs of creating new and temporary beds in emergency shelters and not to permanently increase the capacity of the shelter
For the unsheltered set aside, can a psh project utilize capital costs (acquisition and rehabilitation) from home-arp as a source of match?
In order to be considered eligible matching contributions, the other funds must be committed to the CoC Program funded project and must meet the requirements of 24 CFR 578.37. This means, in general, that matching funds are used on costs and program participants that are eligible under the CoC Program and the Special NOFO.
In general, costs for acquisition, new construction, and rehabilitation funded under the HOME-ARP Program, could be used as matching funds for a CoC Program funded project; however, the recipient will want to ensure that it can meet both the requirements of the HOME-ARP Notice, the CoC Program interim rule, and this Special NOFO before determining if HOME-ARP can be used as match for your CoC Program funded project.
If you have a question about a specific cost or requirement for HOME-ARP, please reach out to your local CPD Field Office as this email box cannot answer questions about HOME-ARP.
In general, costs for acquisition, new construction, and rehabilitation funded under the HOME-ARP Program, could be used as matching funds for a CoC Program funded project; however, the recipient will want to ensure that it can meet both the requirements of the HOME-ARP Notice, the CoC Program interim rule, and this Special NOFO before determining if HOME-ARP can be used as match for your CoC Program funded project.
If you have a question about a specific cost or requirement for HOME-ARP, please reach out to your local CPD Field Office as this email box cannot answer questions about HOME-ARP.
For the rural set aside, could staff incentives be used to support all/any agency staff even if staff aren't funded by the programs in the Special noFo?
In general, capacity building funds awarded under this Special NOFO must be used to pay for capacity building activities for staff that are engaged in assisting program participants receiving assistance through the project (e.g., case management staff, the executive director of the recipient or subrecipient agency overseeing the project). This means you could not, for example, pay a financial incentive to a recipient staff person who spends 100% of their time assisting non-homeless households receiving assistance entirely through another funding source.
As a reminder, Section V.B.3.e.(2) of this Special NOFO authorizes the costs of capacity building activities (paragraph (iv) of this section) for applicants applying for projects under the Rural Set Aside. Project applicants may apply for up to 20% of funds requested for the project for capacity building activities. Eligible capacity building activities include employee education, job training, staff retention activities such and financial incentives to staff, staff training and professional licensing or certification, and other professional development activities.
As a reminder, Section V.B.3.e.(2) of this Special NOFO authorizes the costs of capacity building activities (paragraph (iv) of this section) for applicants applying for projects under the Rural Set Aside. Project applicants may apply for up to 20% of funds requested for the project for capacity building activities. Eligible capacity building activities include employee education, job training, staff retention activities such and financial incentives to staff, staff training and professional licensing or certification, and other professional development activities.
For the Capacity Building Activity, under the Repairs for $10,000 per structure. Does the guidance of repairs activities have to follow CFR 24 578.45 Rehabilitation as well as 24 CFR 578.81 Term of Commitment, Repayment of Grants and Prevention of Undue Benefits?
Section V.B.3.(e)(2)(b)(iii) of the Special NOFO makes eligible, for projects awarded funding under the Rural Set Aside:
• Repairs, (such as insulation, window repair, door repair, roof repair, and repairs) that are necessary to make housing habitable to be used for transitional or permanent housing by people experiencing homelessness. The total cost of repairs may not exceed $10,000 per structure.
In making this activity eligible it does not apply the requirements of 24 CFR 578.45 - rehabilitation - or 24 CFR 578.81 - term of commitment, repayment of grants and prevention of undue benefits. HUD expects all housing in which program participants are housed to meet Housing Quality Standards as established in 24 CFR 578.75(b) as well as state and local building code. As for the minimum period of time that a unit must be used as housing under this program, the recipient or subrecipient has discretion of the requirements that it places on the landlord when agreeing to repair their unit (e.g., requiring the landlord to house people experiencing homelessness in the unit for a minimum period of time). Any requirements should be stipulated in writing and agreed to by both parties prior to beginning the repairs.
• Repairs, (such as insulation, window repair, door repair, roof repair, and repairs) that are necessary to make housing habitable to be used for transitional or permanent housing by people experiencing homelessness. The total cost of repairs may not exceed $10,000 per structure.
In making this activity eligible it does not apply the requirements of 24 CFR 578.45 - rehabilitation - or 24 CFR 578.81 - term of commitment, repayment of grants and prevention of undue benefits. HUD expects all housing in which program participants are housed to meet Housing Quality Standards as established in 24 CFR 578.75(b) as well as state and local building code. As for the minimum period of time that a unit must be used as housing under this program, the recipient or subrecipient has discretion of the requirements that it places on the landlord when agreeing to repair their unit (e.g., requiring the landlord to house people experiencing homelessness in the unit for a minimum period of time). Any requirements should be stipulated in writing and agreed to by both parties prior to beginning the repairs.
For a SSO-Standalone project can the supportive services support already existing programming?
While SSO projects funded under this NOFO could support existing programming, all SSO projects funded under this NOFO must increase the capacity of the recipient to serve more program participants or provide new services as part of the program to people experiencing homelessness. Funding under this NOFO cannot be used to replace existing funding used to provide these services to people experiencing homelessness.
For the Rural Set Aside, under the Rural Capacity Activities for the “Rent or utility assistance after 2 months of nonpayment of rent or utilities to prevent eviction or loss of utility service. Funds may be used to pay rent or utility arrear payments up to 6 months on behalf of program participants residing in permanent housing.”
Is this component supposed to be provided along the normal Homeless Prevention process? Such as the eligible documentation or program enrollment? For instance, will a RRH program enroll them into their program even if they are just providing this activity to someone who is still housed.
Is this component supposed to be provided along the normal Homeless Prevention process? Such as the eligible documentation or program enrollment? For instance, will a RRH program enroll them into their program even if they are just providing this activity to someone who is still housed.
As provided under Section V.B.3.e.(2) of the Special NOFO, the activities authorized by Section 491 of the McKinney-Vento Act are eligible under any of the project types eligible under this Special NOFO - SSO, PH, or Joint-TH an PH:RRH Component project.
In e-snaps, these costs are entered on the supportive services budget line item. For example, if you are providing RRH assistance, and you want to be able to pay for rent or utility arrears for program participants, you would apply for a PH: RRH project and include this cost in the supportive services budget.
Regarding your question about the eligible activity of rent or utility assistance after 2 months of nonpayment of rent or utilities, you could use this activity to pay rental arrears for existing program participants who get behind on their portion of rent or utilities or for new program participants who qualify for assistance and have past due rent and utilities that will prevent them from obtaining or maintaining housing.
As a reminder, as provided in Section II.B.4 of the NOFO, projects have the following eligibility criteria:
Keep in mind, however, as part of its Plan for Serving Individuals and Families with Severe Service Needs required in Section VII.B.4, CoCs must describe how they will prioritize households experiencing or with histories of unsheltered homelessness for the resources awarded under this Special NOFO. And, all projects must be consistent with the CoC's Plan as required by Section II.B.4.c of this NOFO.
In e-snaps, these costs are entered on the supportive services budget line item. For example, if you are providing RRH assistance, and you want to be able to pay for rent or utility arrears for program participants, you would apply for a PH: RRH project and include this cost in the supportive services budget.
Regarding your question about the eligible activity of rent or utility assistance after 2 months of nonpayment of rent or utilities, you could use this activity to pay rental arrears for existing program participants who get behind on their portion of rent or utilities or for new program participants who qualify for assistance and have past due rent and utilities that will prevent them from obtaining or maintaining housing.
As a reminder, as provided in Section II.B.4 of the NOFO, projects have the following eligibility criteria:
- Projects funded through the Unsheltered Homelessness Set Aside may serve individuals and families that meet the criteria of paragraph (1) or (4) of the definition of homelessness at 24 CFR 578.3. Except, if an individual is qualifying under paragraph (1) of the definition of homeless, if that individual or family is coming from transitional housing they must have originally come from places not meant for human habitation, emergency shelter, safe haven, or institution where they resided for 90 days or less and originally came from places not meant for human habitation, safe havens, or emergency shelters.
- Projects funded through the Rural Set Aside may serve individuals and families who meet any of the criteria of the definition of "homeless" in 24 CFR 578.3, except that in order to serve individuals and families meeting paragraph (3) of the definition the CoC must receive approval to do so.
Keep in mind, however, as part of its Plan for Serving Individuals and Families with Severe Service Needs required in Section VII.B.4, CoCs must describe how they will prioritize households experiencing or with histories of unsheltered homelessness for the resources awarded under this Special NOFO. And, all projects must be consistent with the CoC's Plan as required by Section II.B.4.c of this NOFO.